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Preliminary Determination

Outokumpu Stainless USA, LLC

503-0106

Introduction

On June 23, 2014, Outokumpu Stainless USA, LLC submitted an air permit application for the facility

located at 1 ThyssenKrupp Drive, Calvert, Alabama. Additional information was received on September

10, 2014 and January 27, 2017. The facility has proposed to modify the existing NOX and SO2 emissions

limits associated with the Electric Arc Furnace Baghouse (LO-1). Outokumpu proposes to increase the

NOX emission limit from 0.35 lb/ton and 43.97 lb/hr to 0.60 lb/ton and 75.60 lb/hr, and the SO2 emission

limit from 0.15 lb/ton and 18.9 lb/hr to 0.375 lb/ton and 47.25 lb/hr.

Process Description

The production of stainless steel starts with the processing of stainless steel scrap and various alloys in

the electric arc furnace (EAF). Numerous additives are also included in the melt such as lime to remove

impurities. To produce stainless steel, elemental carbon and sulfur must be removed from the molten

steel. This is accomplished in the Argon-Oxygen Decarburization (AOD) vessel. Adjustment of the final

composition of specific grades of stainless steels is accomplished by adding chromium, nickel, and other

alloying agents in ladle metallurgical stations (LMS). Once the melt has attained the specified

composition at the ladles (which have a preheater), the molten steel is poured into a tundish (with

preheaters) which feeds a continuous caster. The caster produces a continuous bar. Water is sprayed

on the bar to solidify the steel. A torch then cuts the bar into individual slabs that are taken to a slab

grinder before proceeding to a hot strip. The EAF and Raw Material Handling and Storage are controlled

by Baghouse # 1 (LO-1) and the AOD and LMS are controlled by Baghouse # 2 (LO-2).

PSD

The proposed modification would qualify as a major source modification since the emissions of NOX and

SO2 would be increased more than the significant emissions rated listed in ADEM Admin. Code R. 335-3-

14-.04(1)(w). The proposed major modification would be subject to ADEM Admin. Code R. 335-3-14-.04

which was adopted pursuant to the federal requirements for prevention of significant deterioration

(PSD).

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PSD regulations were designed to limit pollutant concentration increases in areas that are cleaner than

the National Ambient Air Quality Standards (NAAQS). The regulations establish increments that set

ceilings on the amount of increased ambient pollutant concentrations that will be allowed in a PSD area.

Sources subject to PSD regulations must comply with specific pre-construction review requirements.

A major source or major modification under a PSD review must be constructed with Best Available

Control Technology (BACT). Additionally, the effects on soils, vegetation, visibility, and ambient air

quality must be addressed for each applicable pollutant. If the net air emissions increase of any

applicable pollutant is less than its significance emission rate, PSD does not apply for that pollutant.

The following table shows the PSD significant emissions increase threshold values and emission

increases as specified in the application submitted:

Pollutant PSD Significant

Emission Rate (TPY)

Proposed Emission

Rate Increase (TPY) Significant Source

Sulfur Dioxide (SO2) 40 124 YES

Nitrogen Oxides (NOX) 40 358 YES

BACT

The Clean Air Act prescribes several technology-based limitations affecting new or modified air pollution

sources. Among these limitations is BACT. New or modified major sources must be constructed with

BACT, which is determined on a case-by-case basis, and addresses the energy, environmental, economic,

and other costs associated with each alternative technology, and the benefit of reduced emissions that

technology would bring.

Electric Arc Furnace

NOX

During the EAF process, there are periods when the electric arc operates in an oxidizing gas

atmosphere, wherein the nitrogen in the air in combination with extremely high plasma

temperatures leads to the formation of thermal NOX gas species in the arc. In addition, high

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temperature post combustion occurs with air in the furnace freeboard and primary off-gas system of

the EAF, accounting for additional NOX formation.

Outokumpu examined the following technologies potentially applicable to conventional boilers and

heaters: over-fire air, low excess air, burners out of service, flue gas recirculation, oxy-fuel systems,

direct evacuation control, selective catalytic reduction, selective non-catalytic reduction, three-way

catalysts (non-selective catalytic reduction), and proper equipment design, proper operation, and

good engineering practices. Outokumpu determined that over-fire air would be technically

infeasible because it has only been proven on large utility boilers, and the over-fire air technique is

fundamentally inconsistent with the design criterion for an EAF which relies on an electric arc rather

than fuel combustion based burner to provide heat. The low excess air technique and burners out

of service technique are also fundamentally inconsistent with the design criterion for an EAF which

relies on an electric arc rather than fuel combustion based burners to provide heat, therefore

Outokumpu determined them to be technically infeasible. Outokumpu determined that flue gas

recirculation would be technically infeasible because the recirculation of the flue gas would create

cool spots in the EAF, and create undesirable particulate matter in the EAF as additional natural gas

fired burners would need to be installed to account of the loss of the even distribution of heat. The

use of selective catalytic reduction and selective non-catalytic reduction requires relatively stable air

flow and specific temperature ranges which the air flow from the EAF doesn’t meet, therefore

Outokumpu determined that the selective catalytic reduction and selective non-catalytic reduction

techniques are technically infeasible. Three-way catalysts have been demonstrated almost

exclusively on rich burn engines and not on EAFs therefore Outokumpu determined this technique

to be technically infeasible. The use of oxy-fuel systems creates an oxygen enriched environment in

the EAF which undermines Outokumpu’s ability to produce high-grade chrome stainless steel due to

the excess oxidation of chromium; however, Outokumpu has determined that adding silicon at the

proper concentration will prevent excess chromium oxidation. Therefore, the oxy-fuel system is a

technically feasible option.

Outokumpu proposes the use of an oxy-fuel system, direct evacuation control, establishing and

implementing proper equipment design, proper operation, and good engineering practices, and an

emission rate of 0.60 lb/ton (75.60 lb/hr) for BACT.

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A review of the RACT/BACT/LAER Clearinghouse revealed that the proposed control design would

provide NOX control that is at least as stringent as most of the other BACT determinations for similar

sources. Therefore, the proposed control design listed above is considered BACT for NOX emissions

from the electric arc furnace.

SO2

The formation of SO2 from an EAF is primarily associated with the combustion of sulfur compounds

contained in the scrap and any other materials charged into the furnace. The quantity of SO2

emission generated by operating an EAF depends on the sulfur content of the scrap material, the

sulfur content of the oil on the surface of the scrap metal and sulfur content of any substituted

charge materials.

Outokumpu examined the following technologies potentially applicable to the electric arc furnace:

charge substitution, flue gas desulfurization, sorbent injection, chemical additives, scrap

management plan, and proper equipment design, proper operation, and good engineering practices.

Outokumpu determined that flue gas desulfurization would be technically infeasible as the flue gas

desulfurization system requires an inlet gas temperature between 300°F and 700°F which the EAF

gas stream doesn’t meet. For sorbet injection CaCO3 or Ca(OH)2 in injected into the upper part of a

furnace, but only within a temperature range of 1382°F to 2282°F. The production of molten steel

occurs at temperatures between 2900°F and 3000°F, therefore Outokumpu determined that

sorbent injection would be technically infeasible as the temperature EAF exceeds the temperature

range for sorbent injection. Using a scrap management plan as a means to reduce sulfur bearing

scraps would require plant personnel to test each scrap batch which is not practical due to market

demanded production timelines, therefore Outokumpu determined that a scrap management plan

would be technically infeasible.

Outokumpu proposes the use of charge substitution by using only low-sulfur coal as charge (less

than 1% sulfur by weight, the use chemical additives by adding lime to the EAF (at least 2.5 metric

tons of lime per batch (heat)), establishing and implementing proper equipment design, proper

operation, and good engineering practices, and an emission rate of 0.375 lb/ton (47.25 lb/hr) for

BACT.

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A review of the RACT/BACT/LAER Clearinghouse revealed that the proposed control design would

provide SO2 control that is at least as stringent as most of the other BACT determinations for similar

sources. Therefore, the proposed control design listed above is considered BACT for SO2 emissions

from the electric arc furnace.

Air Quality Analysis

An applicant for a PSD permit is required to conduct an air quality analysis of the ambient impacts

associated with the construction and operation of the proposed new sources or modification. The main

purpose of the air quality analysis is to demonstrate that new emissions from a proposed major

stationary source or major modification will not cause or contribute to a violation of any applicable

National Ambient Air Quality Standards (NAAQS) or PSD increment. Ambient impacts of non-criteria

pollutants must also be evaluated. Generally the analysis will include (1) an assessment of existing air

quality, which may include ambient monitoring data and air quality dispersion modeling results, and (2)

predictions, using dispersion modeling, of ambient concentrations that will result from the applicant’s

proposed project and future growth associated with the project.

National Ambient Air Quality Standards (NAAQS)

The NAAQS are maximum concentration “ceilings” measured in terms of the total concentration of a

pollutant in the atmosphere. The following table presents the applicable standards for the

pollutants under PSD review:

Pollutant/Averaging Time Primary Standard Secondary Standard

Nitrogen Dioxide

NO2, annual 53 ppb 53 ppb

NO2, 1-hour 100 ppb ---

Sulfur Dioxide

SO2, 1-hour 75 ppb ---

S02, 3-hour --- 0.5 ppm

A complete review of the air quality analysis can be found in Attachment 1. As can be seen from the

review, all of the predicted pollutant concentrations are less than the NAAQS and the NAAQS for

each pollutant are not expected to be exceeded.

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PSD Increment

PSD increment is the maximum allowable increase in concentration that is allowed to occur above a

baseline concentration for a pollutant. The baseline concentration is defined for each pollutant (and

relevant averaging time) and, in general, is ambient concentration existing at the time that the first

complete PSD permit application affecting the area is submitted. Significant deterioration is said to

occur when the amount of new pollution would exceed the applicable PSD increment. The air

quality cannot deteriorate beyond the concentration allowed by the applicable NAAQS, even if not

all of the PSD increment is consumed.

The PSD requirements provide for a system of area classifications which affords an opportunity to

identify local land use goals. There are three area classifications. Each classification differs in terms

of the amount of growth it would permit before significant air quality deterioration would be

deemed to occur. Class I areas have the smallest increments and thus allow only a small degree of

air quality deterioration. Class II areas can accommodate normal well-managed industrial growth.

Class III areas have the largest increments and thereby provide for larger amount of development

than either Class I or Class II areas. Presently, there are no Class III areas in the country. The table

below shows the pollutants and associated Class I and II PSD increments.

Pollutant Averaging Period Class I (µg/m3) Class II (µg/m3)

SO2 Annual 2 20

SO2 24-hour 5 91

SO2 3-hour 25 512

NO2 Annual 2.5 25

The following is a brief synopsis of each class area and how it relates to this project:

Class I Areas:

Class I Areas have the smallest increments and thus allow only a small degree of air quality

deterioration. Air Permit applications forms submitted document that the closest Class I Area, the

Breton Wildlife Refuge, is over 100 km from the facility. Therefore, no Class I Area analysis was

required.

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Class II Areas:

Class II areas can accommodate normal well-managed industrial growth. Outokumpu Stainless USA,

LLC is located in a Class II Area. Attachment No. 1 provides a review of the PSD Class II increment

analysis. As can be seen from the review, there are no predicted violations of the Class II increment

for any averaging period.

Class III Areas:

Class III areas have the largest increments and thereby provide for larger amount of development

than either Class I or Class II areas. Presently, there are no Class III areas in the state of Alabama.

Therefore, no Class III area analysis was performed for this project.

Additional Impact Analysis

All PSD permit applicants must prepare an additional impact analysis, for each pollutant subject to

regulation, which would be emitted by the proposed new source or modification. This analysis assesses

the impacts of air, ground, and water pollution on soils, vegetation, and visibility caused by an increase

in emissions and from associated growth. The additional impact analysis generally has three parts:

(a) Growth

(b) Soils and Vegetation

(c) Visibility Impairment

Growth

The proposed modification to increase the EAF BACT emission limits will not involve an expansion of

plant activities. The proposed project will not result in increased residential or commercial growth in

the area. Outokumpu will continue to follow the current rate of hiring from the existing workforce in

the local area. Therefore, there will be no increase in emissions due to growth and conducting

additional modeling is not required.

Soils and Vegetation

As the impacts from the proposed modification will be less than all NAAQS, which are intended to

protect human health and are more stringent than standards intended to protect soil or vegetation,

the project is not expected to have a significant impact on the surrounding soil. Modeled impacts of

SO2 and annual NO2 are less than the SIL. In addition, the project is not expected to emit any toxic

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pollutants in significant quantities which could potentially impair surrounding vegetation nor is the

project expected to impact wildlife in the surrounding area. In summary, the project is not expected

to result in significant impact on soil, vegetation, or wildlife in the area surrounding the facility.

Visibility Impairment

The PSD regulations require that an analysis be performed to assess the impact from the proposed

source on visibility relative to any Class I areas. Since there are no Class I Areas or sensitive scenic

vistas located near the Outokumpu’s facility, a Class I ambient air quality impact analysis was not

required.

Analysis of Non-Criteria Pollutants/Air Toxics Review

There would be no increase of air toxics as a result of modification; therefore no air toxics review was

performed.

NSPS

The existing EAF, AOD, control devices, and dust handling systems are subject to New Source

Performance Standards (NSPS) 40 CFR Part 60, Subpart AAa – Standards of Performance for Steel Plants:

Electric Arc Furnaces and Argon – Oxygen Decarburization Vessels Constructed After August 7, 1983.

Subpart AAa specifically regulates particulate matter emissions to 0.0052 grains/dscf and 3 percent

opacity at the control device, 6 percent opacity from the shop due solely to the operations of the

electric arc furnace, and 10 percent opacity from the dust handling system. The rule also requires the

installation of a continuous opacity monitoring system (COMs) on each baghouse controlling an EAF or

AOD. BACT limits are at least as stringent as the NSPS, 40 CFR Part 60, Subpart AAa.

NESHAP/MACT

The existing EAF, AOD, and control devices are not subject to any NESHAPs/MACTs.

Recommendation

Based on the above analysis, I recommend that, pending the completion of the appropriate public

comment period, the following Air Permit be issued with the attached provisos (See Attachment 2):

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503-0106-X001 Melt Shop – LO Including:

• 126 tph Electric Arc Furnace w/DEC and Elephant House vented to

Baghouse 1 (LO1)

• Argon-Oxygen Decarburization Converter w/Elephant House and 2

Ladle Metallurgy Stations vented to common Baghouse 2(LO2)

• Alloys, Scrap, and Lime Hoppers vented to Baghouses (LO5 & LO12)

• Deslagging vented to Melt shop Baghouse 1 (LO1)

• Continuous Caster vented Melt shop Baghouse 2 (LO2)

• Torch Cutoff vented to Baghouse (LO11)

• Slab Grinding vented to Baghouse (LO4)

• Ladle Preheat Stands w/ Low NOx Burners (LO3 & LO10)

________________________ ________________________

Ryan Cowart Jennifer Youngpeter

Industrial Minerals Section Industrial Minerals Section

Energy Branch Energy Branch

Air Division Air Division

September 17, 2014 April 18, 2017

Date Date

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ATTACHMENT NO. 1

Air Quality Analysis

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ATTACHMENT NO. 2

Proposed Permit

AIR PERMIT

PERMITTEE: Outokumpu Stainless USA, LLC

FACILITY NAME: Outokumpu Stainless USA, LLC

LOCATION: Calvert, AL

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

503-0106-X001 Melt Shop – LO Including: • 126 tph Electric Arc Furnace w/DEC and Elephant House

vented to Baghouse 1 (LO1) • Argon-Oxygen Decarburization Converter w/Elephant

House and 2 Ladle Metallurgy Stations vented to common Baghouse 2(LO2)

• Alloys, Scrap, and Lime Hoppers vented to Baghouses (LO5 & LO12)

• Deslagging vented to Melt shop Baghouse 1 (LO1) • Continuous Caster vented Melt shop Baghouse 2 (LO2) • Torch Cutoff vented to Baghouse (LO11) • Slab Grinding vented to Baghouse (LO4) • Ladle Preheat Stands w/ Low NOx Burners (LO3 & LO10)

In accordance with and subject to the provisions of the Alabama Air Pollution Control Act of

1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the conditions set forth in this permit, the Permittee is hereby authorized to construct, install and use the equipment, device or other article described above.

ISSUANCE DATE: DRAFT

Alabama Department of Environmental Management Page 1 of 9

OUTOKUMPU STAINLESS USA, LLC CALVERT, ALABAMA

(PERMIT NUMBER: 503-0106-X001) PROVISOS

1. This permit is issued on the basis of Rules and Regulations Existing on the date of

issuance. In the event additional Rules and Regulations are adopted, it shall be the permit holder’s responsibility to comply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator

must apply for a permit within 30 days. 3. A new permit application must be made for new sources, replacements, alterations or

design changes which may result in the issuance of, or an increase in the issuance of, air contaminants, or the use of which may eliminate or reduce or control the issuance of air contaminants.

4. In case of shutdown of air pollution control equipment for scheduled maintenance for

a period greater than 30 minutes, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emissions source.

5. In the event there is a breakdown of equipment in such a manner as to cause increased

emission of air contaminants for a period greater than two (2) hours, the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including the duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

6. All air pollution control devices and capture systems for which this permit is issued

shall be maintained and operated at all time in a manner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

7. Submittal of other reports regarding monitoring records, fuel analyses, operating

rates, and equipment malfunctions may be required as authorized in the Department’s air pollution control rules and regulations.

8. Additions and revisions to the conditions of this Permit will be made, if necessary, to

ensure that the Department’s air pollution control rules and regulations are not violated.

9. Nothing in this permit or conditions thereto shall negate any authority granted to the

Air Division pursuant to the Alabama Environmental Management Act or regulations issued thereunder.

10. On completion of construction of the device for which this permit is issued,

notification of the fact is to be given to the Chief of the Air Division. Authorization

Air Permit No. 503-0106-X001

to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of construction and/or operation without authorization could result in revocation of this permit.

11. This unit shall be provided with sampling ports, ladders, platforms, and other safety

equipment to facilitate testing performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

12. Prior to a date to be specified by the Chief of the Air Division in the authorization to

operate, emission tests are to be conducted on Meltshop Baghouse 1 (LO1) by persons familiar with and using the EPA Sampling Train and Test Procedure as described in the Code of Federal Regulations, Title 40, Part 60, for the following pollutants. Written tests results are to be reported to the Department within 30 working days of completion of testing.

Particulates ( ) Carbon Monoxide ( ) Sulfur Dioxide ( ) Nitrogen Oxides (XX) Volatile Organic Compounds

( ) Visible Emissions ( )

Lead ( ) *Test to be performed in accordance with NSPS Subpart AAa

13. Emissions tests are to be conducted for the following pollutants at intervals not to

exceed 12 months following the date of the initial compliance testing. All reports shall be submitted to the Department within 30 days of completion of the testing.

Particulates (XX*) Carbon Monoxide (XX) Sulfur Dioxide ( ) Nitrogen Oxides (XX) Volatile Organic Compounds

( ) Visible Emissions ( )

*Test to be performed in accordance with NSPS Subpart AAa

14. If the performance tests for nitrogen oxides for at least 2 consecutive years show

emissions are at or below 50% of the emission limit, and there are no changes in the operation or control equipment, the Permittee may petition the Department to discontinue the annual tests.

15. The Department must be notified in writing at least 10 working days in advance of all

emission tests to be conducted and submitted as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(1) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing company that will conduct the tests.

Air Permit No. 503-0106-X001

(2) A complete description of each sampling train to be used, including type of media used in determining gas stream components, type of probe lining, type of filter media, and probe cleaning method and solvent to be used (if test procedure requires probe cleaning).

(3) A description of the process(es) to be tested, including the feed rate, any operating parameter used to control or influence the operations, and the rated capacity.

(4) A sketch or sketches showing sampling point locations and their relative positions to the nearest upstream and downstream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the required attendees will be determined on a case-by-case basis. All test reports must be submitted to the Department within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the Department.

16. Any performance tests required shall be conducted and data reduced in accordance

with the test methods and procedures contained in each specific permit condition unless the Director (1) specifies or approves, in specific cases, the use of a reference method with minor changes in methodology, (2) approves the use of an equivalent method, or (3) approves the use of an alternative method, the results of which he has determined to be adequate for indicating whether a specific source is in compliance.

17. The following emission limits shall apply to Meltshop Baghouse 1 (LO1) associated

with the electric arc furnace:

Pollutant

Emissions Limit

(lb/ton)

Emission Limit (lb/hr)

Test Method

NOx 0.60 75.60 7E

CO 2.0 251.14 10

VOC (as C) 0.03 3.77 18 or 25A

PM/PM10 0.0018* 10.72 5

SO2 0.375 47.25 CEMS, 6, or 6C

Pb 0.047 12 *The units for the PM limit is gr/dscf

Air Permit No. 503-0106-X001

18. The following emission limits shall apply to Meltshop Baghouse 2 (LO2) associated with the argon oxygen decarburization (AOD) vessel and ladle metallurgy stations:

Pollutant

Emissions Limit

(lb/ton steel)

Emission Limit (lb/hr)

Test Method

NOx 0.35 43.97 7E

CO 2.0 251.14 10

VOC (as C) 0.03 3.77 18 or 25A

PM/PM10 0.0018* 10.72 5

SO2 0.15 18.84 CEMS, 6, or 6C

Pb 0.00534 12 *The units for the PM limit is gr/dscf

19. The opacity of emissions from Baghouse LO1 and Baghouse LO2 shall not exceed

that designated as 3% opacity as determined by the continuous opacity monitoring system (COMS).

20. Emissions from the roof or any openings of the building enclosure associated with the electric arc furnace and argon-oxygen decarburization vessel shall not exceed six percent (6%) opacity as determined by a six (6) minute average.

21. The electric arc furnace and AOD vessel shall be located in an enclosure (elephant

house) located inside the meltshop building. This enclosure (elephant house) shall be equipped with a capture system, which shall be routed to the Meltshop Baghouses. The system shall be operated in a manner such that an optimum pressure is maintained on the elephant house.

22. The production of molten steel from this electric arc furnace shall not exceed

1,100,000 tons in any consecutive 12-month period. Records of monthly and rolling 12-month total steel production shall be kept in a form suitable for inspection for a period of at least five years following recording.

23. Emissions of particulate matter from the Alloys, Scrap, and Lime Hoppers (LO5 &

LO12) shall not exceed 0.0018 gr/dscf and 2.09 lb/hr, each, as determined by EPA Reference Method 5 as found in Appendix A of 40 CFR part 60 (latest edition).

24. Emissions of particulate matter from the Slab Grinding (LO4) shall not exceed 0.005

gr/dscf and 1.35 lb/hr, each, as determined by EPA Reference Method 5 as found in Appendix A of 40 CFR part 60 (latest edition).

25. Emissions of particulate matter from the Torch Cutoff (LO11) shall not exceed

0.0018 gr/dscf and 0.765 lb/hr as determined by EPA Reference Method 5 as found in Appendix A of 40 CFR part 60 (latest edition).

Air Permit No. 503-0106-X001

26. The opacity of emissions from the slab grinding, slab cutting, and material handling

(LO4, LO5, LO11, & LO12) shall not exceed that designated as 10% opacity as determined by EPA Reference Method 9 as found in Appendix A of 40 CFR part 60 (latest edition).

27. The sources covered by this permit shall fire only natural gas as a fuel.

28. The sulfur content of the coal charged into the EAF shall not exceed 1.0% by weight.

29. The Permittee shall monitor and keep a record the sulfur content from each load of coal received to be used as charge in the EAF. The Permittee may use vendor test data or shipment certifications to verify the sulfur content in the coal. If the sulfur content in the coal is greater than 1.0%, the Department must be notified within 24 hours. These records shall be kept on site for a period of at least five years.

30. The Permittee shall add at least 2.5 metric tons of lime per batch (heat) of steel produced.

31. The Permittee shall keep a record of the amount of lime added per batch (heat) of steel produced. These records shall be kept on site for a period of at least five years.

32. The electric arc furnace and argon oxygen decarburization vessel are subject to 40 CFR part 60, subpart AAa – Standards of Performance for Steel Plants: Electric Arc Furnaces and Argon-Oxygen Decarburization Vessels Constructed After August 17, 1983 to include the following:

a. The permittee shall adhere to the monitoring standards in

§60.273a(a),(b),(d) and §60.274a(a),(b),(c),(d),(e),(f),(g),(h). b. The permittee shall adhere to the Test Methods and Procedures in

§60.275a(a),(b),(c),(d),(e),(f),(g),(h),(i),(j). c. The permittee shall adhere to the Recordkeeping and Reporting standards

in §60.276a(a),(b),(c),(d),(e),(f),(g). 33. The opacity of emissions from any dust handling system shall not exceed 10%

opacity as determined by EPA Reference Method 9 as found in Appendix A of 40 CFR part 60 (latest edition).

34. All dust handling systems (screw conveyors, silos, hoppers, etc.) from the baghouse

hoppers shall be enclosed to prevent fugitive emission from these handling systems. 35. The emissions from Baghouse LO1 and Baghouse LO2 shall each be vented through

a conventional stack that shall be equipped with a continuous opacity monitoring system (COMS). The COMS shall be installed, maintained, and operated in conformance to Appendix B of 40 CFR part 60.

Air Permit No. 503-0106-X001

36. A continuous emissions monitoring system (CEMS) for SO2, conforming to the specifications of Appendix F of 40 CFR part 60, shall be installed, operated, and maintained on the exhausts of Baghouse LO1 and Baghouse LO2.

37. For emissions from Meltshop Baghouse 1 (LO1) and Meltshop Baghouse 2 (LO2), a

report of excess emissions, as defined below, will be submitted to the Department for each calendar quarter within 30 days following the end of the quarter. The reports will include, at a minimum, the following information:

a. Opacity. The excess emissions over 3% as computed from six-minute averages.

SO2. The excess emissions over 47.25 lb/hr (LO1) and 18.84 lb/hr (LO2) calculated from 3-hour averages.

Note: Data recorded during periods of system breakdowns, repairs, adjustments, and calibration checks shall not be included in any of the above data averages.

b. The date and time of commencement and completion of each time period of excess emissions.

c. The nature of the cause of the excess emissions (if known). The date and time identifying each period during which the monitoring systems were inoperative (except for zero and span checks) and the nature of the system repairs or adjustments.

d. Equations used to convert SO2 emission data as monitored to the required reporting standard (lbs/hr) will be included with the reports.

e. When no excess emissions have occurred and the monitoring systems were not inoperative or did not require repairs or adjustments, such information shall be stated in the reports.

All the original data charts, performance evaluations, calibration checks, adjustments and maintenance records and other information regarding the monitoring systems will be maintained in a permanent form suitable for inspection. The file shall be retained for at least five years following the date of such recording.

38. Deviations from permit requirements shall be reported within 48 hours or 2 working

days of such deviations, including those attributable to upset conditions as defined in the permit. The report will include the probable cause of said deviations, and any corrective actions or preventive measures that were taken

39. This permit is issued with the condition that, should obnoxious odors arising from the

plant operations be verified by Air Division inspectors, measures abate the odorous emissions shall be taken upon a determination by the Alabama Department of Environmental Management that these measures are technically and economically feasible.

Air Permit No. 503-0106-X001

40. A drawing or diagram showing roadway areas connected to the meltshop shall be

submitted to the Department. The drawing should indicate which roads would be paved.

41. All paved roads connected to the meltshop shall be swept or flushed of surface

material at least every 5 days. 42. Paved road flushing specified in Proviso 37 is not required when the temperature is

below 32°F. Paved road or area cleaning is not required when precipitation during the previous 24-hour period has exceeded 0.01 inches.

43. The Permittee shall perform a visual check, at least once per day, of the stacks

associated with this unit. This check shall be performed by a person familiar with Method 9. If any visible emissions are noted, and are not corrected within a period of one hour, then a Method 9 must be performed within 4 hours of the initial observation. Maintenance shall be performed as needed. Any repairs or observed problems shall be recorded.

44. The permittee shall maintain at the plant, and make available for inspection, records

documenting each occasion on which paved areas are cleaned and each occasion on which paved areas are not cleaned according to the required schedule, including justification for failure to meet the required schedule, such as equipment breakdown or appropriate weather conditions.

45. Precautions shall be taken to prevent fugitive dust emanating from unpaved plant

roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.

Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water at any time the surface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffic to a point below that at which dust

emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time the road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above methods fail to adequately reduce airborne dust from plant or haul roads and grounds, alternative methods shall be employed, either exclusively or in combination with one or all of the above control

Air Permit No. 503-0106-X001

techniques, so that dust will not become airborne. Alternative methods shall be approved by the Department prior to utilization.

46. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit would have required halting or reducing the permitted activity.

47. The issuance of this permit does not convey any property rights of any sort, or any

exclusive privilege.

48. The Permittee shall submit an annual compliance certification to the Department annually within 60 days following the end of each calendar year. The compliance certification shall include the following:

a. The identification of each term or condition of this permit that is the basis of the certification.

b. The compliance status, whether continuous or intermittent. c. The method(s) used for determining the compliance status of the source,

currently and over the reporting period. d. Other facts the Department may require to determine the compliance

status of the source.

DRAFT

Date